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Canadian pilots could be adding naps and flying time limitations to their flight plans
under a new policy Transport Canada proposed March 25 in the Canada Gazette, Part
I.

The new policy would require companies to integrate annual flight time and flight
duty time limitations and rules on rest periods and time free from duty. It would
also require fatigue risk management systems, as well as tougher “fit for duty” requirements.
The rules would be implemented through amendments to the Canadian Aviation Regulations,
which are expected to be published for public comment later this year, Transport Canada
said March 25 in their notice of intent.

But many in the industry say parts of the proposal don’t appear to reflect the compromises
that were reached among various industry sectors and players. Some elements of the
chart showing the proposed duty day for pilots were changed without corresponding
changes to other parts of the proposal, according to Capt. Dan Adamus, president of
the Canadian arm of the international Air Line Pilots Association.

“For us, it’s starting to get watered down,” Adamus told Bloomberg BNA. Further analysis
will be needed, but it also appears some proposals that were previously all-encompassing
have now been limited, he said.

The pilots group, which has championed the need for more stringent rules, is also
pushing for faster implementation times among smaller airlines.

Major carriers will implement the fatigue management rules within 12 months after
the regulatory amendments are finalized, according to Capt. Dan Adamus, president
of the pilots group. But smaller carriers will not have to implement the rules until
48 months after they are finalized. A 24-month delay for smaller carriers would be
more appropriate, Adamus said.

Adamus suggested that some industry groups don’t support all of the proposed changes,
as they’re looking at the potential impact of the changes on their costs rather than
the need to boost operating safety.

However, the National Airlines Council of Canada commended the government for the
fatigue management initiative, as safety is the “number one priority” for its members,
Grant Dingwall, the association’s manager of research and public affairs, said March
29.

“We can’t comment on the specific proposals at this time, as we are still reviewing
the details and what they mean for our carriers, but we look forward to continuing
to consult with Transport Canada on this important file,” Dingwall told Bloomberg
BNA in an email.

Based on a meeting between industry representatives and Transport Canada officials
on March 24, it seems likely that the detailed proposals published with the notice
of intent are nearing a final version, Adamus said. It seems likely the regulations
will be published in draft form in June 2017 and finalized by late fall, he said.

Consultations Started in 2010

Transport Canada said it first engaged industry on the issue of flight crew fatigue
management in 2010 by establishing a working group to review the requirements introduced
under International Civil Aviation Organization standards in 2009.

Their August 2012 final report’s recommendations, alongside an internal Transport
Canada technical committee, led to a notice of proposed amendment that was subject
to a review process conducted by the Canadian Aviation Regulation Advisory Council.

Stakeholder feedback led to the proposal of a two-phase approach to bring Canadian
rules into line with scientific fatigue principles and international standards—the
first involving rules for major airlines and the second phase to all other operators,
it said. Further feedback led to a decision that proposed amendments would be introduced
for major airlines, commuter airlines and air taxi operators, but would not apply
to private operators, it said.

The Transport Canada notice is open to public comment through April 24.

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